Data Privacy

Section A (privacy policy for visiting and using our website)

Protecting the security and privacy of your personal information is very important to ASSAB Tooling Technology (Shanghai) Co., Ltd., (hereinafter “we” and “us”). We observe the applicable legal regulations for the protection, proper handling and confidentiality of personal information, especially the EU General Data Protection Regulation (“GDPR”), the Personal Information Protection Law (“PIPL”) in the People’s Republic of China and other relevant data protection laws. In this privacy policy, the terms “personal data” and “personal information” are used interchangeably, depending on the applicable law.

This privacy policy explains the nature, scope and purpose of us collecting and using your personal information when you visit and use our website

Personal information

Personal information is any information relating to the data subject (natural person), who can be identified, directly or indirectly (e.g. name, e-mail address or IP address).

Collection and Use of Information

When you use our products and services, we need to collect and use your personal information, including the following:

  1. In order to fulfill the basic features of providing our products and services to you, you must authorise us to collect and use the necessary information. If you refuse to provide the corresponding information, you will not be able to use our products and services in a proper manner;
  2. In order to provide you with additional features of our products and services, you may choose to consent or not to consent individually to the information that we collect and use. If you refuse to provide the information, you will not be able to use the additional features nor achieve the functional effects that we intend to achieve; however, it will not affect your use of our basic features.


When you contact us by e-mail, phone or via our website, in order to assist you to fully understand your use of our products and services, we will collect the personal information you submit (e.g. name, e-mail, mobile phone number, office phone number, your inquiry or order(s) and relevant documents) to process your inquiry or order(s), including but not limited to fulfillment of your order(s), complying with legal obligations and communication with you.


Our website uses cookies that allow the website to recognize your browser when you visit the website again. Cookies are small text files that the browser stores on your device. This allows the website to be optimally adapted to your interests. If you do not want cookies to be stored on your computer, you can set up your browser to inform you when cookies are set so that you can decide whether to allow them on a case-by-case basis. You can also deactivate use of cookies in your browser. Please note that in this case, you will not be able to use all of the website functions to their full extent.

Google Analytics

This website uses Google Analytics, a Google Inc. (Google) web analysis service. Google Analytics uses cookies, which are text files stored on your computer to be able to analyze your use of the website. The information generated by the cookies about your use of this website is usually transferred to a Google server in the USA and stored there. We only use Google Analytics with activated IP address anonymization. This means that within the member states of the European Union or in other states parties to the agreement within the European Economic Area, Google truncates your IP address before it is transferred. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and truncated there. On behalf of the website operator, Google will use this information to evaluate your website use and compile reports on website activity and to provide the website operator other services related to website use and Internet use. The IP address transmitted by your browser during Google analytics will not be combined with other Google data. You can refuse the use of cookies by selecting the appropriate settings on your browser, but note that in this case, you will not be able to use all of the website functions to their fullest extent. You can also prevent Google from collecting and processing the data generated by the cookies based on your website use (including your IP address) by downloading and installing the browser plug-in available at the following link:

For more information on the terms of service and data protection, see: and

Baidu Analytics

We and Baidu collect, after user has given permission, certain types of usage information when you visit our website or use Baidu Products. When you use a Baidu Product, Baidu may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and let Baidu help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Baidu Product (e.g., the pages you view, the links you click, how frequently you access the Baidu Product, and other actions you take on the Baidu Product), and allow us to track your usage of the Baidu Product over time. We may collect log file information from your browser or mobile device each time you access the Baidu Product. Log file information may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, information about your mobile device, referring / exit pages and URLs, number of clicks and how you interact with links on the Baidu Product, domain names, landing pages, pages viewed, and other such information. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Baidu Product and to understand more about the demographics of our users. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third-party applications, and other information that assists us in analyzing and improving the Baidu Product.

When you access a Baidu Product by or through a mobile device, Baidu may receive or collect and store a unique identification number associated with your device or the Baidu Product (including, for example, a unique device ID, Unique ID for Advertisers (“IDFA”), Google Ad ID, or Windows Advertising ID), MAC address, mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and longitude) or similar information regarding the location of your mobile device.

We may use the data collected through cookies, log file, device identifiers, location data and clear gifs information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide customised, personalized content and information, including targeted content and advertising; (c) provide and monitor the effectiveness of Baidu Products; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website and Baidu Products; (e) diagnose or fix technology problems; and (f) otherwise to plan for and enhance Baidu Products.

Legal basis, storage periods

Data processing takes place on the basis of GDPR and PIPL.

The processed personal data is used for statistical analysis and for the purpose of operating, safeguarding, and optimizing the website (legitimate interest). Any other use of your personal data (e.g. sending of newsletters) only takes place with your written consent.

Unless explicitly indicated otherwise at the time of the collection of your personal data (e.g. in a declaration of consent), your personal data will be erased (or anonymized) if the retention of the personal data is no longer necessary to fulfill the purposes for which they were collected and if no statutory retention obligations (such as tax or commercial law) require us to further retain the data.

You may also delete some of your information under “review, correct and add information” or you can request for cancellation of account to delete all your information. Once you have deleted the relevant information or we have assisted you in deleting the relevant information, we will not be able to delete the corresponding information from our backup systems immediately, due to the applicable legal and security technical restrictions. We will store your personal information securely and restrict any further processing of it, until the backup data can be deleted or anonymised.

Transfer and disclosure of personal information

Without your consent, we will not transfer your personal information collected (based on your website use) to third parties, unless it is required to perform our duties or required by law/authorities.

We engage processors (service providers) to process personal information (within the scope of an IT support contract, for example). These processors are contractually bound to comply with the applicable information protection regulations.

Openstreet Maps

Our website includes openstreet maps functions. These functions are offered by Openstreet Map Foundation, St. John’s Innovation Centre. Data is also transferred to Openstreet Map. Note that we, as the site provider, do not receive any information about the content of the transferred data or its use by Openstreet Map. For more information, see Openstreet Map’s privacy policy at


Our website includes heatmap and tracking functions. These functions are offered by Mouseflow, Inc. Data is also transferred to Mouseflow. When you visit such websites or mobile applications, we may receive certain information about your behaviour including user activity, page content, click/touch, movement, scroll, and keystroke activity (in some cases). For more information, see Mouseflow’s privacy policy at

Your rights, contact details

Generally, you have the right of access, the right to rectification, erasure, restriction of processing, information portability, and the right to object. If processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Finally, you are entitled to file a complaint with a supervisory authority.

For any questions related to data privacy and asserting the rights listed above, please contact the relevant personnel at

This privacy policy will be revised from time to time.

Section B (privacy provisions for making enquries / placing orders with us)

Sharing of Personal Information

You agree to share the following personal information with us. We will use your employee’s name and email address (collectively, “Employee Information“) for direct marketing and promotional purposes in accordance with our Privacy Policy (“Privacy Policy“). Both parties agree and acknowledge that such Employee Information shall be considered as personal information, while we are each an independent processor for personal information (as defined in PIPL) and should each determine the purposes and methods to process Employee Information.

You shall assist us with the collection of Employee Information and obtaining of the consent, including (a) providing adequate processing notices to all relevant data subjects in an appropriate manner in accordance with China data protection laws, as required by China data protection laws (including but not limited to, in accordance with this Privacy Policy); and (b) obtaining all necessary consents and authorizations to process Employee Information in accordance with China  data protection laws. You should provide these information and documents to us upon request.

Collection and Processing of Business Contact Information

We may collect and process your business contact information (including but not limited to name, job title, contact number, email address, business address, social media accounts (if any)) to ensure that you are able to perform your obligations under the relevant agreement(s). We may provide the business contact information to our affiliates and any other third parties located within or outside mainland China, if necessary. We will store business contact information in order to fulfil the information processing purposes, to the extent permitted under the China data protection laws.

You hereby declare and warrant that you will inform your executive officers and contact persons who are the data subjects about this clause and obtain their express consent for us to collect, process and share their business contact information in accordance with this clause.

Assistance and Notification

You shall provide us with reasonable assistance to respond to data subjects’ requests, complaints or inquiries, or any requests or inquiries from government authorities. If you receive (i) a request or query from a data subject in relation to that person’s personal information and such request or query relates to our obligations under applicable data protection laws, or (ii) a complaint or request that relates to our obligations under applicable data protection laws, you shall promptly (without undue delay) notify us in writing and cooperate with us for the necessary action.

Both parties shall comply with the China data protection laws in relation to the obligations under this agreement, the processing of personal information and any other relevant obligations under this agreement. You shall provide reasonable assistance, information and cooperation upon our request, to ensure that we comply with our obligations under the China data protection laws.

Security Measures

Both parties shall take and maintain appropriate technical, operational and organisational measures, these measures shall at least comply with the statutory requirements of China data protection laws to ensure the safety of personal information.

Indemnity and Liability without Limitation

Notwithstanding anything contrary to the parties’ agreement, you shall fully indemnify, keep indemnified, and hold harmless against our affiliates and us from any and all losses, damages, responsibilities, liabilities and expenses, including reasonable attorneys’ fees and expert fees and all other costs that we and our affiliates may incur to defend our affiliates and us against any third party’s claims, demands, suits or causes of action. These are the responsibilities that arise out of or in connection with your failure to comply with your obligations under this agreement and applicable data protection laws.